Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:06-cv-00935-MMS

Document 31

Filed 05/07/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS SEMINOLE NATION OF OKLAHOMA, Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) )

No.: 06-CV-935-L Judge George W. Miller

PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME WITHIN WHICH TO FILE PLAINTIFF'S REPLY TO DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION FOR DOCUMENT PRESERVATION ORDER, CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims, Plaintiff respectfully submits this unopposed motion for enlargement of time within which to file Plaintiff's Reply to Defendant's Response to Plaintiff's Motion for Document Preservation Order, Confidentiality Agreement and Protective Order. Plaintiff respectfully requests the enlargement of time to and including May 19, 2008. Under the Court's scheduling order, the current filing deadline for Plaintiff's Reply is May 9, 2008. Docket No. (Doc. #) 29. Plaintiff requests this enlargement of time for the following reasons: 1. Undersigned Plaintiff's counsel has been drafting a proposed document

preservation order and confidentiality agreement and protective order aimed at reaching a compromise between the parties for these documents. 2. Plaintiff's counsel has not yet had the opportunity to provide Defendant's

counsel with these documents for review. 3. Plaintiff's counsel would like the opportunity to reach a compromise on

the proposed orders.

Case 1:06-cv-00935-MMS

Document 31

Filed 05/07/2008

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4.

Plaintiff's counsel believes a good faith effort at reaching a compromise on

these documents would be an efficient use of the parties' time and resources. 5. Plaintiff's counsel conferred with Defendant's counsel on May 7, 2008,

regarding this motion for enlargement of time, and Defendant's counsel authorized undersigned counsel to state that Defendant does not oppose the motion. Respectfully submitted this 7th day of May, 2008. s/ Sandra Benischek Harrison___________ SANDRA BENISCHEK HARRISON, OBA #18647 Andrews Davis, P.C. 100 North Broadway Avenue, Suite 3300 Oklahoma City, OK Tel: (405) 272-9241 Fax: (405) 235-8786 [email protected] ATTORNEY OF RECORD FOR PLAINTIFF OF COUNSEL: MICHAEL D. MCMAHAN, OBA #17317 Andrews Davis, P.C 100 North Broadway Avenue, Suite 3300 Oklahoma City, OK 73102 Tel: (405) 272-9241 Fax: (405) 235-8786 JENNIFER HENSHAW MCBEE, OBA #19170 Andrews Davis, P.C 100 North Broadway Avenue, Suite 3300 Oklahoma City, OK 73102 Tel: (405) 272-9241 Fax: (405) 235-8786 JACQUELYN V DUFFY, OBA #21630 Andrews Davis, P.C. 100 North Broadway, Suite 3300 Oklahoma City, OK 73102 Tel: (405) 272-9241 Fax: (405) 235-8786

Case 1:06-cv-00935-MMS

Document 31

Filed 05/07/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME WITHIN WHICH TO FILE REPLY TO DEFENDANT'S RESPONSE TOPLAINTIFF'S MOTION FOR DOCUMENT PRESERVATION ORDER, CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER was served on May 7, 2008, by Electronic Case Filing, on the following counsel: TERRY M. PETRIE Attorney of Record Environment & Natural Resources Division United States Department of Justice 1961 Stout Street, 8th Floor Denver, CO 80294 Tel: (303) 844-1369 Fax: (303) 844-1350 [email protected] ATTORNEY OF RECORD FOR DEFENDANT OF COUNSEL: ANTHONY P. HOANG United States Department of Justice Environment & Natural Resources Division PO Box 663 Washington, DC 20044-0663 Tel: (202) 305-0241 Fax: (202) 353-2021 [email protected]

___s/ Sandra Benischek Harrison___

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